Skip to content

Courts on AI / Fabricated or misquoted citations

Mitchell v. HIG Realty Credit Fund, L.P.

Court of Appeals of Georgia · State appellate courts · GA · · No. A26A0854 · opinion

The Court of Appeals of Georgia affirms summary judgment for HIG Realty Credit Fund and warns Trentiss Mitchell about citations in his self-represented appellate briefing. The court identifies two non-existent cases and two unrelated cases, says the defects suggest unchecked generative AI, and declines sanctions.

Disposition
The court affirmed summary judgment and warned Mitchell that future fictitious or inapplicable citations may result in sanctions.
Recorded conduct
Self-represented appellant cited two nonexistent cases and two unrelated cases for propositions in his appellate brief. — outcome: warning; actor: litigant in person
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

As an initial matter, we note that in his appellate briefing, Mitchell cites five cases that are either fictitious or have nothing to do with the propositions for which they are cited.1 These defects suggest that Mitchell’s briefs were “drafted with the use of unchecked generative AI,”2 and his reliance on non-existent law is a clear impediment to the work of this Court.3 We elect not to sanction Mitchell because HIG has not complained and does not appear to have been hampered in responding to Mitchell’s arguments.4 Nevertheless, we caution Mitchell that any future filings in this Court containing citations to fictitious or plainly inapplicable cases may result in the imposition of sanctions.5 ... Mitchell purports to cite Walker v. Pierce, 315 Ga. App. 524 (2012), and Crenshaw v. Ga. Dep’t of Human Resources, 263 Ga. 722 (1994), which do not exist. He also cites Henson v. Columbus Bank & Trust Co., 144 Ga. App. 80 (240 SE2d 284) (1977), and Stamps v. Nelson, 290 Ga. App. 277 (659 SE2d 697) (2008), which do exist, but have nothing to do with the issues raised in this appeal.

Authorities cited in the passage: Walker v. Pierce, 315 Ga. App. 524 (2012) · Crenshaw v. Georgia Department of Human Resources, 263 Ga. 722 (1994) · Henson v. Columbus Bank & Trust Co., 144 Ga. App. 80 (1977) · Stamps v. Nelson, 290 Ga. App. 277 (2008) · Slay v. Ross, 379 Ga. App. 1 (2026) · Shahid v. Essam, 376 Ga. App. 145 (2025) · Court of Appeals Rule 7(e)(2)

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub